My app was rejected based on: Guideline 3.2.2 - Other Business Model Issues - Unacceptable

My app allows users to compete in quizzes with other players, with each quiz having a $5 entry fee.

The winner of the quiz will receive a digital gift card. The amount of the gift card depends on the number of players in the quiz.

This app has gone through a long review process. It initially failed to Guideline 5.1.1:

We found in our review that your app does not meet all of our requirements for apps that offer highly regulated services or handle sensitive user data. Specifically:

The account that submits the app must be enrolled in the Apple Developer Program as an organization, and not as an individual.

Which made me to believe it was a Gambling app (even though it's a skill-based game, not a chance-based game which is what 'Gambling' is defined as).

So I established a company and then resubmitted the app. It then failed on the following guideline:

Guideline 3.2.2 - Business - Other Business Model Issues - Unacceptable

The primary purpose of your app is to encourage users to watch ads or perform marketing-oriented tasks, which is not appropriate for the App Store.

I was then entitled to a call to explain the rejection. The reviewer said that you are not allowed to give anything of real value (money, gift cards etc) as an incentive to users. He said I could only give in-app rewards (like increased levels in the app).

I found this hard to believe - as there are many pay-to-win puzzle/quiz games (Skillz alone has many of these apps: https://games.skillz.com/genres/Puzzle).

So what is the best way to appeal to the App Review Board? Do I just write the same explanation I just said above?

I also asked which specific dot point in 3.2.2 the app was breaching and he was not able to answer: https://developer.apple.com/app-store/review/guidelines/#unacceptable

Any feedback appreciated.

My app was rejected based on: Guideline 3.2.2 - Other Business Model Issues - Unacceptable
 
 
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